Hudson City Sav. Bank v. Commissioner
United States Tax Court
A mutual savings bank on the accrual basis of accounting declared that interest on deposits for the second 6 months of 1962, 1963, and 1964 was payable on the first business day of January in each of the succeeding years. In practice, depositors were permitted to withdraw the interest on any of the last 3 days of December.
Read the full summary
A mutual savings bank on the accrual basis of accounting declared that interest on deposits for the second 6 months of 1962, 1963, and 1964 was payable on the first business day of January in each of the succeeding years. In practice, depositors were permitted to withdraw the interest on any of the last 3 days of December. Held: (1) The interest is deductible exclusively under sec. 591, I.R.C. 1954, and not sec. 163(a); (2) the interest is deductible in the later, not earlier, years because it was not "withdrawable" until January; and (3) the interest amount at year end is a "liability" and…
1Opinion of the Court
Hudson City Savings Bank, Petitioner v. Commissioner of Internal Revenue, Respondent
Hudson City Sav. Bank v. Commissioner
Docket No. 2716-67
United States Tax Court
53 T.C. 70; 1969 U.S. Tax Ct. LEXIS 39;
October 23, 1969, Filed
Decision will be entered under Rule 50.
A mutual savings bank on the accrual basis of accounting declared that interest on deposits for the second 6 months of 1962, 1963, and 1964 was payable on the first business day of January in each of the succeeding years. In practice, depositors were permitted to withdraw the interest on any of the last 3 days of December. Held: (1)…
2Cases cited9 opinions
- United States v. AndersonSupreme Court of the United States · 1926
- Bulova Watch Co. v. United StatesSupreme Court of the United States · 1961
- Peoples Bank & Trust Co. v. CommissionerUnited States Tax Court · 1968
- Peoples Bank and Trust Company v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1969
- Shepherd Constr. Co. v. CommissionerUnited States Tax Court · 1969
4 more not listed; retrieve them via the Exa API.